The Moment of Truth on Audits

AAHomecare has been to the Hill, CMS, GAO, OIG and everywhere in between, speaking passionately about the problems with Medicare audits and how they are crushing an industry already under pressure. Out there on the front lines of this battle, the most frequent response from policymakers comes in the form of a question:

“Do you have any data to back up your statements?”

“Can you show me with numbers how this is affecting your industry?”

That is the moment of truth, because we do not have any data and we cannot numerically show how this is affecting our industry.

The industry must be able to demonstrate the burdensome nature of audits, in terms of both volume and overturn rates. If we cannot accurately detail how the industry is being impacted, we will not be able to succeed in obtaining needed reform to the audit process.

That’s why more than a year ago, AAHomecare started a project called the HME Audit Key. The goal of the HME Audit Key is to answer these questions by collecting data from suppliers about how many audits are happening at each level and where they are in the appeals process.

The results are going to be used to drive much-needed improvements in the Medicare audit system. The companies who participate are going to have the added benefits of using the results to identify audit trends within their company, educate staff and take measures to prevent future audits.

Where Are We Today?

A group of industry stakeholders made up of suppliers, consultants and attorneys have spent many hours developing the survey and the web based application for the HME Audit Key. The biggest challenge the group faced was how to collect the needed data without making the survey too complicated to complete. If the data collection was too difficult, then suppliers would balk at the time and resources necessary to complete the survey.

Phase 1 testing has been completed. This involved logging into the web-based application and entering miscellaneous data. The goal was to ensure the main functionality worked well, so that when real information was entered, things would go smoothly.

Phase 2 testing was where the rubber met the road.

Participants from 27 of the most engaged and vocal HME companies who had been following the progress of the project agreed to participate in a real-world test of the system. However, faced with gathering and inputting real audit data into the application, many encountered roadblocks.

At the close of Phase 2 testing, only 14 companies had fully completed the survey. The most common challenges were:

• No time available to complete the survey.
   
• The company did not track audits and appeals in the manner the survey requested the information.
   
• Suppliers were unable to go back in time to January 1, 2014, to quantify appeals activity.
   

With only 14 of 27 of the most active, vocal and engaged HME companies able to complete the survey, it is difficult to imagine a path forward to a nationwide launch. It was discouraging to hear lack of time cited as one of the top challenges to complete the survey. If HME suppliers want to see progress on this issue, then it must be a treated as a priority.

The project team has already begun working to address the two other most commonly reported challenges. First, knowing that going back to January 1, 2014, was presenting an obstacle, the survey will be changed to only look back at data from the fourth quarter of 2015, October 1, 2015, through December 31, 2015.

Second, through learning that companies are not tracking audits and appeals in the manner that is compatible with the Audit Key, it has become clear that the industry does not have a good mechanism to track audit and appeal activity.

To help suppliers conquer this obstacle, AAHomecare met with the larger software vendors in the HME space several times to discuss the current options available for tracking audits and appeals. Currently, no software vendors are offering a module that handles this type of information and there would be difficulty in creating a module due to competing enhancement priorities. In response, AAHomecare is researching the feasibility of creating an application that can track audits and appeals in a way that will save suppliers time and is compatible with the HME Audit Key.

Going Forward

We know that HME suppliers are feeling the pain. With so many resources tied up in a broken appeals system, where claims and their associated payments can hang in limbo for three years or more, businesses are breaking under the strain. AAHomecare is working on legislative and regulatory initiatives to reform the audit system, but we need the HME Audit Key to be able to demonstrate the burdensome nature of audits. Even with clear challenges in front of us, we can no longer wait to launch the HME Audit Key to the industry.

AAHomecare is opening the enrollment period for the Audit Key. Soon companies will be able to sign up to participate and start the pre-work necessary for the collection phase, which will begin in January 2016. There are three easy steps:

1. Register your company and obtain an organizational ID. This is what protects the anonymity and security of your data.
    
2. Watch soon-to-be-updated HME Audit Key webinars and download the educational materials from the HME Audit Key website. These tools explain what data elements are needed to complete the survey.
    
3. Start building processes that will track the right data elements from the fourth quarter of 2015 in a way that is compatible with the HME Audit Key.
    

In January 2016, all registered suppliers will be notified when they can start inputting their data into the system, which will likely be over a two-week period in January.

If your company has questions about the HME Audit Key, start by taking the first step of registering your company at HMEAuditKey.org. There you can learn more about how the Audit Key works and receive updates on the project. I am happy to answer questions and provide deeper insights on how to get involved. The bottom line is that making a compelling case for audit reform requires this data. Let’s spend less time complaining about audits and more time doing what it takes to make a difference about them.